S Progressive Leaders for Democratic Action at UC

Milonopoulos

Optn/y ay > riiialy Indtptnient *R(j^ to Sent

Complaint Filed By: Theo Milonopoulos — rn Studio City, CA 91604 -- t- om_ om ii; May 30,2014 Jr.S?.V-:-M wtla -rj Hlp-.rn Office of the General Counsel ft U3(p r Federal Elections Commission *_ I 999 E Street, N.W. CO Washington DC, 20463

To the Office of the General Counsel of the Federal Elections Commission:

I write to file a formal complaint alleging possible violations of federal election and campaign finance laws by Marianne Williamson for Congress that is supporting Ms. Marianne Williamson in her campaign to represent California's 33rd Congressional district.

On Thursday, May 29, Progressive Leaders for Democratic Action (FDLA) at UCLA, which presents itself as a student organization at the University of California, Los Angeles, sponsored an event whose advertising was paid for by Marianne Williamson for Congress. The event, called "Progressive Choices: Marianne Williamson," was being presented by PDLA at UCLA to be held on Thursday, May 29, 2014, in the Global Viewpoint Lounge of UCLA Ackerman and was "Sponsored by Progressive Leaders for Democratic Action UCLA," according to an advertisement "Paid For By Marianne Williamson for Congress" (see Appendix A, Figure 1).

When I ai rived at the event around 5:00pm on Thursday evening, 1 did not see any signage about the Progressive Leaders for Democratic Action UCLA. Instead, I saw a large, oversized campaign poster similar to the one documented behind the candidate at the event in tlie May 30, 2014, edition of the UCLA Daily Bruin (see Appendix A, Figure 2). On the table outside the entrance were Marianne Williamson for Congress t-shirts, campaign buttons and volunteer sign up sheets. Nowhere did 1 see any reference at the time to any registered student group at UCLA.

When I introduced myself as a write-in candidate for California's 33rd Congressional district race and asked to speak with an organizer for the event, I was referred not to a student, but to Joe Cicero, chapter president of the Southern California Americans for Democratic Action. When I asked about his affiliation with the Progressive Leaders for Democratic Action at UCLA, he claimed to be an advisor to the organization despite not having a formal UCLA affiliation. When I asked to speak to a student organizer, he introduced me to one several minutes later named Hugh Tra who was wearing a "Marianne Williamson for Congress" t-shirt that is routinely issued by the Marianne Williamson for Congress campaign at political campaign events.

When I walked into the event space, I saw an elaborate fruit, cheese and refreshment display that seemed outside the budget traditionally associated with on-campus, student registered events. Although 1 did not stay through the candidate's actual discussion, the photograph that appears alongside the UCLA Daily Bruin's coverage of the event (see Appendix B) indicates that there was a large, oversized campaign sign on permanent display throughout the event.

Page 1 of 4 Milonopoulos

Optnly day * fitrcely Independtnt * Ready to Serve

I have subsequently spent time investigating the genesis of the student group alleged to have sponsored this event and believe it to be a front organization for supporters of the Marianne Williamson for Congress campaign masquerading as a UCLA student group. According to the organization's social media Facebook page (https://www.facebook.com/PLDABruins), the organization was founded in April 2014 at the University of California, Los Angeles (see Appendix A, Figure 3). The organization allegedly held its first general body meeting on April 24,2014, on the first floor of Holly study lounge at UCLA (see Appendix A, Figure 4).

On May 7,2014, the organization announced on its social media Facebook page that,

PDLA proudly endorses Marianne Williamson for congress [j/c]! Learn more about her and her campaign by clicking the link below! Want to get involved? Come to the PDLA meeting this Friday at 12:30 in SAC Conference Room 5 (3rd Floor) to get more information on how we're getting UCLA students to join in and make progress!

(see Appendix A, Figure 5)

On May 8,2014, the organization announced on its social media Facebook page that.

We are looking for paid canvassers to help out on a congressional race that cover's [jfc] UCLA. The pay is $14 a hour [.v/c] and you can work weekdays or weekends! Shifts are 5 hours long. Please click the link below for more information or email us at [email protected].

(sec Appendix A, Figure 6)

On the same date. May 8, 2014, the Marianne Williamson for Congress campaign announced that it had received the endorsement of the Southern California Americans for Democratic Action, whose above-mentioned president, John Cicero, is quoted in a Marianne Williamson for Congress-generated press release saying.

With so many talented, capable progressives in the race, we wished we could send several of them to Washington. But finally, we think Marianne is the right candidate for these difficult times, and will be an outspoken advocate for economic justice. We need a fo.reeful independent advocate who_is willing to fight for the 99% as our representative in Congress.

(see Appendix C)

On May 15, 2014, the organization created an event on its social media Facebook page for a "Marianne Williamson Pre-Election Rally with Alanis Morissette" taking place on Monday, May 19, 2014, at the Saban Theatre in Beverly Hills, California, a venue that is hot located on the UCLA campus (see Appendix A, Figure 7).

On May 19,2014, the organization posted a photograph on its social media Facebook page of apparent students wearing Marianne Williamson for Congress t-shirts and standing with actress Jane Lynch (see Appendix A, Figure 7).

Page 2 of 4 Milonopoulos

Openly Gay* fiercely Indepeni/ent * Rea^ to Stive

On May 20,2014, the organization posted a series of three photographs of apparent students wearing Marianne Williamson for Congress t-shirts standing behind tables and greeting individuals in what appears to be an official campaign capacity. In one of these photographs is the above-referenced president of the Southern California chapter of the Americans for Democratic Action posing with students allegedly associated with the Progressive Leaders for Democratic Action of UCLA dressed in Marianne Williamson for Congress t-shirts in front of a large, oversized campaign poster for Marianne Williamson for Congress (see Appendix A, Figures 8a-d).

On May 23,2014, the organization created an event on its social media Facebook page called "PDLA Presents Progressive Congressional Candidate: Marianne Williamson" to be held at the Global Viewpoint Lounge in Los Angeles, California (see Appendix A, Figure 9).

4 On May 27, 2014, in a social media Facebook post that was subsequently edited, the ^ organization posted a campaign flyer advertisement paid for by Marianne Williamson for Congress (see Appendix A, Figure 1) with the following accompanying text:

Looks like there were major changes to the line up for this Thursdays [^/c] event! Make sure you come to the Ackeiman Global Viewpoint Lounge this Thursday at 6pra to listen to congressional candidate Marianne Williamson and many Hollywood actors, producers, and writers talk about the American political system and what you can do to help #MakeProgress!

(see Appendix A, Figure 10)

On May 30,2014, the organization posted a photograph that appeared in the May 30, 2014, edition of the UCLA Daily Bruin of Marianne Williamson speaking at the aforementioned event (see Appendix, Figure 2) with the following accompanying text:

We would like to thank everyone who came out to the event last night! We had a great time and we hope you did too! We can't thank Marianne Williamson, Meredith Scott Lynn, Kristen Hahn, and Steven Weber enough for taking the time to talk to UCLA students about the problems facing America. Remember to cast you vote [^/c] in the California primaries on June 3rd! #MakeProgress

(see Appendix A, Figure 11)

The website for the Progressive Leaders for Democratic Action (PDLA) at UCLA (http://progressiveleaders.nationbuilder.com/) is hosted on the same nationbuilder.com platform as the website for the Los Angeles chapter of the American for Democratic Action (http://adasocal.nationbuilder.com), which only deepens my suspicions that the PDLA was established in April 2014 in association with supporters of the Marianne Williamson for Congress campaign from within the ADA leadership to make it appear as though a UCLA student association endorsed her campaign (see Appendix A, Figures 12a-b).

I allege that the Progressive Leaders for Democratic Action (PDLA) at UCLA is a front organization for supporters of Marianne Williamson for Congress masquerading as a student- organized and taxpayer-funded group on the campus of University of California, Los Angeles Page 3 of 4 Milonopoulos

Opinly Gay > Fltnely Indtpendtnt' Ready to Sorvo

(UCLA). If this is indeed the case, the Marianne Williamson for Congress campaign has jeopardized the University of California, Los Angeles's tax-exempt status as a not-for-profit institution under Section 501(c)(3) of the Internal Revenue Code, which prohibits such entities from engaging in political campaigns.

1 also allege that the Marianne Williamson for Congress campaign has violated the spirit if not the letter of federal election and federal campaign finance laws, and I therefore register a formal complaint with the Federal Elections Commission requesting its Office of the General Counsel to investigate this matter to the fullest extent of the law.

1 hereby attest under penalty of perjury that the above complaint is truthful and accurate to the best of my ability, recollection and understanding.

Sincerely,

ThcoMUonopoulo. JEE ATTACHED cc: Marianne Williamson Marianne Williamson for Congress 11645 Wilshire Boulevard, 602 Los Angeles, CA 90025

Kevin S. Reed Vice Chancellor for Legal Affairs Office of the Campus Counsel University of California, Los Angeles Los Angeles, CA 90095

Charles F. Robinson Office of General Counsel University of California Office of the President 1130 K Street, Suite 340 Sacramento, CA 95814

John Cicero President, Southern California Chapter Americans for Democratic Action 3916 South Sepulveda Boulevard Culver City, CA 90230

Page 4 of 4 CALIFORNIA JURAT WITH AFFIANT STATEMENT GOVERNMENT CODE § 8202

• See Attached Document (Notary to cross out lines 1-6 below) • See Statement Below (Lines 1-6 to be completed only by document signer[s], not Notary) i

Signature of Document Signer No. 1 Signature of Document Signer No. 2 (if any)

State of California Subscribed and sworn to (or affirmed) before me

County of Los on this SoA day of 20 /H. by If/7 Year (1). IHS.O MTLo/vjQpouLgy; —

(2). -fvhff. RAMNIK SINGH ( Name(s) of Signer(s) COMri. 1937079 | NOTARY PUOLir-CALlFGRtJIA Q LOS ANGELES COUNTY M proved to me on the basis of satisfactory evidence MY Comm. I to be the personj^-who appeared before me.

Signati Place Notary Seal Above

OPTIONAL-

Though this section is optional, completing this information can deter alteration of the document or fraudulent reattachment of this form to an unintended document.

Description of Attached Document

Title or Type of Document: C**^FLA.2^T

Document Date: —> Number of Pages:

Signer(s) Other Than Named Above:

Optnlf • fit fitly Indipeadeni •Retdy to Sen*

APPENDIX A

Figure 1 Advenisement for Progressive Leaders for Democratic Action at UCLA Event Paid for by Marianne Williamson for Congress PLDA AT UCLA PRESENTS 1 8 PROGRESSIVE CHOICES 0 MARIANNE WILLIAMSON

AND MEREDITH SCOTT LYNN ACTRESS / PRODUCER / ENTREPRENEUR - CO-STARRED IN I ECAilv BLOxiOt FORCES OP NAIUStk. A HIGH I A I THC HOXHUHV

KRISTIN HANN PRODUCER- ?«COtPARrtO rwfi //M£ lffA\/£ltRSWIf£ SWu'CH

STEVEN WEBER ACTOR - WINGS lEAViNGtoS i/CC«S SINGLE VVWIE EEMA(.E

KAREN MCCULLAH SCREENWRITER - L t"0*A£ L >* fitCWOf HOUSG GUf^NY }0 THINCS I ^tATF AGOur vOt' THURSDAY MAY 29 | 6PM GLOBAL VIEWPOINT LOUNGE UCLA ACKERMAN SPONSORED BY PROGRESSIVE LEADERS PGR DEMOCRATIC ACTION UCLA PLDABRUINS.ORG | MARIANNEFORCONGRESS.COM

I PAID FOR BY MARIANNE WILLIAMSON FOR CONGRESS|

Page 1 of 13 Milonopoulos

Opfnly Gay <• fitntly M§pent/inl 'Keidytofiive

Figure 2 Photograph of California 33rd Congressional district candidate Marianne Williamson at event sponsored by UCLA student organization Progressive Leaders for Democratic Action at the UCLA Ackerman Global Viewpoint Lounge on Thursday, May 29, 2014.

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Figure 3 Screenshot of social media Facebook page of Progressive Leaders for Democratic Action of UCLA taken 30-05-2014 at 08:18:52.

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Figure 4 Screenshot of social media Facebook page of Progressive Leaders for Democratic Action of UCLA taken 30-05-2014 at 08:18:52.

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Opmly 6iy ' fitnely Indtpmdtnt 'Reidy M lent

Figure 5 Screenshot of social media Facebook page of Progressive Leaders for Democratic Action of UCLA taken 30-05-2014 at 08:19:27.

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PLOA ^rDud^' encorsis Mai.anne Vi'iihamscn (or congress' Learn rrpre about her and "ei camaaig** by c'lccrg the l-.nli bdow' Wani to get nvolved? Come :o Paid Canvassing the PLOA meeting ihn Friday at 12 2C . 1. , ; • • w 1* ' Roorv S Ord Floo«> to get Tore informa:'onon how n-eVe /• • i i'' S'.i" ••»* «* • '"e •ar'^jas' * »" J getting UCLA itude'cs to jci" ir anc Ta« orogresi! • sr * •. h* • i!;, r e-. -s A ".J • /.»!?•

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Page 4 of 13 Milonopoulos

Openly Cay •' Flenely Indtpindtnl 'Rudy to Strut

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Openly day ^fienely Independent 'Ready to Sene

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Page 6 of 13 Milonopoulos

Optnly Sijr • Firmly ladtptndnl 'Ruify (o Sam

Figure 8a Screenshot of social media Facebook page of Progressive Leaders for Democratic Action of UCLA taken 30-05-2014 at 08:17:21.

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Page 7 of 13 Milonopoulos

OptnlyCsy ritittly Independent KtidyloStne

Figure 8b Photograph downloaded from social media Facebook page of Progressive Leaders for Democratic Action of UCLA on 30-05-2014 at 08:59.

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Page 8 of 13 Milonopoulos

Optitly Ciy fitntly Inieptnilent' Hiady to Sttw

Figure 8d Photograph downloaded from social media Facebook page of Progressive Leaders for Democratic Action of UCLA on 30-05-2014 at 09:00.

Figure 9 Screenshot of social media Facebook page of Progressive Leaders for Democratic Action of UCLA taken 30-05-2014 at 08:18:03.

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Open/y fi*y • fltmly loitpndtnt >Ready ro Senw

Figure 10 Screenshot of social media Facebook page of Progressive Leaders for Democratic Action of UCLA taken 30-05-2014 at 08:16:26.

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Looks like there were major changes to the ii-e up for Like Comment Share this Tnursdays event Make sure you come to the Acker.man Global Viewpoint Lounge this Thursday at 6 pm to listen to congressional candidate .viana-ne Progressive leaders for Democratic Action Will amso- and many Hollywood actors, prooucers. and ar UCLA l.ljv 26 - wr te's talk about the American ooliticai system and what you can do to help 'MakeProgress! What Happened a; LCSBwas tragic Unfo'cunately. it happens every day We 'ave the oooortunity to ten the wo'ld about, me importance of feminism while clarify-ng PLDA AT UCLA the misconceotions benino it. Helo end the War on PRESENTS Women and irMakcPitsgress fYesAIIWorren PROGRESSIVE CHOICES MARIANNE WILLIAMSON What War on Women?

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Page 10 of 13 Milonopoulos

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Figure 11 Screenshot of social media Facebook page of Progressive Leaders for Democratic Action of UCLA taken 31-05-2014 at 12:09:43.

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Progressive Leaders for Democratic Action at UCLA shared The Daily Bruin's photo. 11 hours .jgo

We would like to thank everyone who came out to the event last night! We had a great time and we hope you did tool We can't thank Marianne Williamson, Meredith Scott Lynn, Kristen Hahn, and Steven Weber enough for taking the time to talk to UCLA students about the problems facing America. Remember to cast you vote in the California primaries on June 3rd! ^MakeProgress

Page 11 of 13 Milonopoulos

Openly Gey Fiercely Intfepenilent. Keady to Serve

Figure 12a Screenshot of website of Progressive Leaders for Democratic Action of UCLA (http://progressiveleaders.nationbuiider.com) taken 30-05-2014 at 8:20:03.

Pitjgressiue Leaders TAKE ACTION for Democratic Action Do

Marianne WiUlamson To Talk Progressive Leader's 2014 At UCLA Primary Endorsement List Is NowOutI PDLA AT UCLA pnesErrrs Here IS e snippet ot our PROGRESSIVE CHOICES prograslve endorsement list] MARIANNE WILLIAMSON State elCellfemla: Lieutenant Governor - Gavin Newsom Secretary o!State • Derek Crnsman Controller - Betty Vee Treasurer -John Chiang Attorney General • Kamala Harris MeH»lUKOrfiWiW .< Insurance Commissioner - Dave lanes Superintendent of Public Instruction - Tom Torlakson THURSDAY MAY 29 I 6PM GLOBAL VIEWPOINT LOUNGE Click herefor Che full list of endorsements. UCLA ACKERMAN 3 ••M-.-'alM n leei'M -Iweeei csii^i ••• 9 •0LAa*UN«,O«A'>

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Figure 12b Screenshot of website of Progressive Leaders for Democratic Action of UCLA (http://progrcssiveieaders.nationbuilder.com) taken 30-05-2014 at 8:35:15.

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Page 12 of 13 Milonopoulos

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APPENDIX B

"Candidate Marianne Williamson speaks at Ackerman Thursday," UCLA Daily Bruin, 30 May 2014. 4 I APPENDIX C

"Marianne Williamson Wins Endorsement of the SoCal Americans for Democratic Action," Independent Political Report, May 6, 2014.

Page 13 of 13 Li A/I i (http://dailybruin.com/) In the news: Sexual assault at UCLA (/2014/05/01/ucla-student-groups-combat-college-sexual-assault/) Isia Vista shooting (/tag/isla-vista-shooting/) JazzReggae Festival (/tag/Jazzreggae-'eslival/) Candidate Marianne Williamson speaks at Ackerman Thursday

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Marianne Williamson, a candidate running for a House of Representatives seat, spoke about money In politics at an event hosted by Progressive Leaders for Democratic Action. (Jessica Zhou/Oaiiy Bruin)

May 30, 2014 1:55 am More stories In News (http://dallybruin.com/category/news/)

BV BF.N.IAMIN GFNTA (HTTP://DAILYBRUIN.COM/AUTHOR/CAMAYAK_t54/) TwCCt This post was updated at 8:12 p.m. (https://twitter. Marianne Williamson, a candidate for the House of Representatives for the district where UCL% is located, talked about ways she (https://twitter. hopes to reform government politics in a speecli at UCLA Thursday night. {https://lwitter. (https://www.fa "Democracy is not working. It's not an expression of the American people," she said. "Money in .politics is a cancer that is eating our ii=http://dailyb: democracy." marianne-williai Williamson, wKo'is"fuimingfor office arairindepBndentbecause-shebelie\'es-thebest ideas-coins from outside the-party-system, spoke to students and attendees at Ackerman Global Viewpoint Lounge about how she thinks tnonQ' has a negative influence on politics. Progressive Leaders for Demoaatic Action, which has endorsed Williamson foroffice, hosted the event because the group thinks she is the most progressive of the 18 candidates running. The student club started this quarter because members felt other groups on campus were not promoting a sufficient amount of progressive ideas, said Hugh Tra, the club's president and a fourth-year history student.

According to its website. Progressive Leaders for Democratic Action supports increasing the minimum wage, taking action to combat climate change and extending the student loans repayment grace period from six to 18 months.

Williamson's speech focused on how she thinks the state of the economy dominates the political sphere. She said she thinks the country needs a constitutional amendment to outlaw the influence of money in politics, since it has become too expensive to run for office for the average American.

Williamson emphasized that she thinks politicians are influenced by corporations, who use lobbyists to influence policy.

"1 believe we need a people's movement," Williamson said. "I'm part of tlie group that wants to disrupt the political status quo." . For students, Williamson said she thinks that debts that have lasted more than lo years should be forgiven. If elected, she hopes to institute a plan in which college tuition would be covered for students who commit to one year of public service, including military service.

Williamson said she also wants to reform the prison system and help undocumented individuals obtain legal identification papers. She added that she supports the creation of a Palestinian state. At the event, write-in candidate Theo Milonopoulos was contacted by security after Joe Cicero, the president of the Southern California chapter of Americans for Democratic Action, called university police on him for being disruptive.

Cicero said Milonopoulos handed out campaign materials during the event.

Milonopoulos said Friday that he questions whether the event was held and funded by the student group or Williamson's campaign. Cicero, who is also an adviser for the Progressive Leaders for Democratic Action, said the group applied for funding from the Undergraduate Students Association Council for the event and that it was not funded by the campaign. Milonopoulos said he plans to file a complaint with the Federal Elections Commission to investigate whether the event was a violation of the federal fundraising reporting requirement. On Friday, Milonopoulos also spoke at Meyerhoff Park about mental health and gun control folIov\iiig the shooting near UC Santa Barbara. He said if he is elected, he wa nts to overhaul the counseling and psychological services on college campuses. k The primary elections will take place on June 3. Contributing reports from Emily Uu, Bruin contributor. Email Genta at [email protected] (mailto:bgenta@media:uda.edu).

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4 4 Caiiiciii cii/u/riii/i: siiiti (/if nuilji ismiu i S/31/2014 Marianne Williamson Wins Endorsemenl of the SoCal Americans for Demoeratie Action! Indcpcndeni Rolitica! Report

Marianne Williamson Wins Endorsement of the SoCal Americans for Democratic Action

(The following was posted on Williamson's campaign website.)

LOS ANGELES, GA - The Marianne Williamson for Congress campaign announced that Americans for Democratic Action, SoCal chapter has endorsed Marianne Williamson in District 33 after a candidate forum in Venice May 6. ADA is the oldest liberal political lobby in America, co-founded by Eleanor Roosevelt and other progressive leaders in 1947.

The forum was co-sponsored by SoCal ADA and the Venice Action Alliance. Of the eighteen candidates in the race, six attended to answer questions by panelists and community voters on numerous national and local issues.

"I am honored to receive the endorsement of the SoCal chapter of the ADA," Williamson said. 'The ADA, founded by Eleanor Roosevelt, John Kenneth Galbraith, Walter Reuther, Arthur Schlesinger, and Reinhold Niebuhr was established to keep the New Deal dream alive. I am running for Congress because that New Deal dream - the American Dream - is on the verge of perishing. We need to revive the dream with a Green New Deal, create the opportunity for every child to have access to pre-school, provide free college in exchange for one year of national service, produce serious legislation on climate change and pass a Constitutional Amendment to outlaw the undue influence of money on our politics. Humanitarian rather than economic values should be society's bottom line," said Williamson

Williamson's endorsement of the SoCal ADA follows on the heels of the endorsements by other progressive Congressmen including Rep. Alan Grayson (D-FL), Rep. Keith Ellison (D-MN, co-chair of the Progressive hRp://www.independentpoiiticaireport.coin/20l4/()3/[iiarianne-williamson-wins-cndorseinenl-of-the-socal-americans-for-democra(ic-action/ 1/8 .S/31/201.4 Marianne Wlliianiaon Wins Endorsement of the SoCat Americans for Democratic Action I Independent Political Report Caucus in the House of Representatives), former congressman Dennis Kucinich (D-OH), as weii as social justice activist Van Jones and environmentalist Ed Begieyjr.

Joe Cicero, SoCai ADA President said, "With so many talented, capable progressives in the race, we wished we couid send several of them to Washington. But finally, we think Marianne is the right candidate for these difficult times and will be an outspoken advocate for economic Justice. We need a forceful independent advocate who is willing to fight for the 99% as our representative in Congress."

Forum coordinator John Seeley continued, 'Winnowing our choice to Ted Lieu, an energetic and savvy legislator we've endorsed before, and Marianne Williamson, a fresh and visionary voice focused on the critical issue of saving democracy from big money, ADA ultimately decided on Marianne. While Ted has many pluses, his recent abandonment of affirmative action - the key to preventing a permanent black and i brown underclass - was a deal-breaker."